On behalf of the Virginia Dietetic Association and over 2500 Dietetic professionals in the Commonwealth of Virginia, I am writing in response to the review of regulations governing standards for Dietitians during the public comment  period.  We strongly advocate for regulation of Registered Dietitians (RDs) to protect the health of Virginians and for maximum stability and safeguarding of jobs for thousands of Dietitians.    

RDs should be regulated at the state level because they are the only health care professionals uniquely trained in Medical Nutrition Therapy (MNT) to work side by side with medical doctors to improve health outcomes and reduce health care costs of patients with chronic kidney disease, diabetes, hyperlipidemia, and many other serious conditions.  The level of training and expertise of our RDs, as part of the healthcare team, is so strong, comprehensive, and evidence based that the Centers for Medicaid and Medicare (CMS) allow RDs to bill for services as direct providers of MNT.

We are seeking licensure for RDs in Virginia in the upcoming legislative session to assure the appropriate regulation of our profession on the State level.  Missing in the Commonwealth of Virginia are true disciplinary and quality safeguards that would be accomplished through licensure. National registration does not ensure that dietitians in Virginia are meeting standards of care, obeying the law, and have not been disciplined in other jurisdictions. Nothing in Virginia law prevents dietitians who have lost licenses in other states from moving to Virginia to continue their practice.  Additionally, disciplinary actions on a state level do not automatically revoke national registration. Currently Virginia regulates the practice of Dietetics, ensuring a minimal competency level, by requiring participation in a national registration process through the American Dietetic Association, soon to be called the Academy of Nutrition and Dietetics. Virginia also exclusively reserves the title of Dietitian to those health practitioners who have successfully registered through this process.  However, national registration does not address the adequate and necessary regulation of the practice of dietetics that can only be achieved through licensure by the Commonwealth.

The field of dietetics is a profession that needs regulation by the state to ensure consistent quality of care. There are dietitians in hospitals calculating tube feedings and intravenous feedings for adults, children and those in intensive care units, in long term care facilities, working with wound care nurses on adequate protein consumption, in dialysis centers guiding patients on low potassium and other mineral specific diets, as well as in private practice counseling clients with diabetes on changing lifestyle behaviors for cost saving outcomes.  We are also in schools, gyms, food service and education advocating for healthier food choices to prevent diseases.  Regulation of RDs in Virginia has no impact on nutrition related businesses. 

Dietitians are required to complete both an academic program and dietetic internship program accredited by the Commission on Accreditation for Dietetics Education.  These rigorous, science based programs attract highly qualified candidates on the both the undergraduate and graduate levels.  Our training is comparable to other health professionals found in clinical settings, such as nurses, physical therapists and social workers.  Virginia’s universities (UVA, VCU/MCVH, VSU, VT, JMU, Radford, and Norfolk State University) and the Virginia Department of Health provide this training for potential dietitians.   The final step before practicing as an RD is passing the national registration exam.   In order to maintain this national registration status, RDs are required to adhere to the processes of the Commission on Dietetic Registration through continuing professional education as long as they practice in the dietetic profession. 

The Virginia Dietetic Association, therefore, recommends continued regulation of Registered Dietitians.